ML20050A430

Responds to 820111 Request for Views on Constituent G Cook Fact Sheet.All Listed Concerns within NRC Jurisdiction Have Been or Are Being Reviewed.Record Copy

ML20050A430
Person / Time
Site:	Perry
Issue date:	03/24/1982
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Glenn J SENATE
References
NUDOCS 8204010283
Download: ML20050A430 (13)

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,/ q The Honorable John Glenn b_

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Dear Senator Glenn:

This is in response to your January 11, 1982 request that the Commission's staff provide its views on a fact sheet, " Notes on the Perry Nuclear Plant,"

and three media clippings from one of your constituents, Ms. Genevieve Cook.

During the licensing review of the Perry application, all of Ms. Cook's concerns that fall within the scope of our jurisdiction have been or are presently under review by the staff. Some of these concerns have been fully resolved to cur satisfaction while others are awaiting further infomation or study. A few of these concerns were fully litigated during the construction permit hearing held from 1974 to 1977 All of the remain-ing concerns that are appropriate to the Commission's scope of review will be addressed during the operating license review which is currently underway.

Some of these concerns have been admitted as contentions for an operating license hearing which is currently expected to begin in Painesv1110, Ohio, later this fall. Construction of the plant is not expected to be completed until late 1983.

Prior to the start of the operating license hearing, the staff will document the results of its safety and environmental review. A Dra ft Environmental Statement (DES) is scheduled to be issued in the next few wteks and finalized in a Final Environmental Statement (FES) this summer. A Safety Evaluation Report (SER) covering the bulk of our review is currently expected to be issued in May 1982. One or more supplements are likely to be required to resolve all issues. The first such supplement is targeted for issuance in July 1982. All of Ms. Cook's concerns that are within our scope of review will be addressed in these documents.

Notwithstanding the fact tl:at our review is still in progress, we are en-closing responses to Ms. Cook's concerns consistent with this fact.

I hope this information will be helpful for you to respond to your consti-tuent.

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See next page The Honorable John Glenn United States Senate Washington, D.C.

20510

Dear Senator Glenn:

This is in response to your January 11, 1982 request that the Commission's staff provide its views on a fact sheet, " Notes on the Perry Nuclear Plant,"

and three media clippings from one of your constituents. Ms. Genevieve Cook.

During the licensing review of the Perry application, all of Ms. Cook's concerns that fall within the scope of our jurisdiction have been or are presently under review by the staff. Some of these concerns have been fully resolved to our satisfaction while others are awaiting further information or study. A few of these concerns were fully litigated during the construction permit hearing held from 1974 to 1977.

All of the remain-ing concerns that are appropriate to the Commission's scope of review will be addressed during the operating license review which is currently underway.

Some of these concerns have been admitted as contentions for an operating license hearing which is currently expected to begin in Painesville, Ohio, later this fall. Construction of the plant is not expected to be completed until late 1983.

Prior to the start of the operating license hearing, the staff will document the results of its safety and environmental review. A Draft Environmental Statement (DES) is scheduled to be issued in the next few weeks and finalized in a Final Environmental Statement (FES) this summer. A Safety Evaluation Report (SER) covering the bulk of our review is currently expected to be issued in May 1982. One or more supplements are likely to be required to resolve all issues. The first such supplement is targeted for issuance in July 1982. All of Ms. Cook's concerns that are within our scope of review will be addressed in these documents.

Notwithstanding the fact that our review is still in progress, we are en-closing responses to M. Cook's concerns consistent with this fact.

I hope this information will be helpful for you to respond to your consti -

tuent.

l Sincerely, (Signed) T. A Rehm ELD

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EDO JThessin Willian J. Dircks WJDircks 3/Y/82 f

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ENCLOSURE Commission's Staff Responses to Ms. Cook's Concerns about the Perry Nuclear Plant 0

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Commints on herry Plant Concerns Concern No. 1 and 2 There are four schools within three miles of the Perry reactors, two of them elementary. The Perry Township High School by the old Atomic Energy Com-mission regulations would be in the exclusion zone. Within 10 miles are the Madison high school, middle school, and a couple elementary schools.

All roadways North of I-90 are two-lane, so that in case of accident and evacuation, long strings of school busses could be bogged down and stalled in traffic. Children, who are more susceptible to radiation injury than adults, would inevitably be forced to breathe considerable radiation-con-taminated air.

(9 schools within 5 miles; 32 schools within 10 miles; insufficient buses)

Access to I-90, the nearest major throughway, is midway of Madison at Route 528.

Route 2 ends between Perry and Painesville and parallels the westerly exit or access to I-90.

East-West traffic on I-90 with a northerly wind would be traveling for miles in radiation-contaminated air. There is no adequate North-South route out of the area.

Lake County wants Cleveland Electric to cover the costs of disaster services.

Response

These concerns are associated with the Perry Plant Emergency Plan. The Plan in its current form, Appendix 13A to the Final Safety Analysis Report (FSAR), addresses the evacuation of school children and area evacuation routes.

These matters were discussed at the prehearing conference in Painesville, Ohio on June 2,1981.

The applicant is aware of these con-cerns and is assisting the local communities ia the development of the local emergency plan to resolve them.

For evacuation routing, the appli-cant has indicated that the Ohio State Highway Patrol and local police forces will be mobilized to maintain traffic flow and exclusion from some roadways, if necessary.

The Emergency Plan must meet our requirements prior to issuance of an operating license for power levels above 5%.

The Energency Plan has been admitted as a contention to the operating license hearing (expected to begin in November 1982).

The Lake County Board of Commissioners have been granted status as a party to this pro-ceeding.

Their primary interest in the proceedings is in regard to the development and financing of the local off-site emergency plan.

Concern No. 3 Highways to and from the reactor site are inadequate for the 40,000 to 45,000 cu. ft. of low-level radioactive wastes which must be transported away each year.

On-site storage would be most unsuitable in the Perry area with its ground water problems.

Response

Based on experience to date at operating nJclear plants, the staff has no reason to expect that the hauling of Perry low level wastes will be a major safety or traffic problem.

Low level radioactive waste will be

typically enclosed in 50 or 200 cu. ft containers for shipment. A normal truck could easily transport four-200 cu. ft. containers, each approxi-mately 5' x 5' x 8' in size. At that rate, the annual low level waste could be removed in 50 to 57 separate truck trips. This number of tr' ck u

shipments should not significantly impact local traffic.

The applicant' has proposed only temporary on-site storage of low level waste whilo awaiting shipment to off-site repositories.

Thus, the leak-tight con-tainers should prevent any low level waste from entering the groundwater during this temporary storage period.

Concern No. 4 Construction of the reactors at Perry was halted several times because of seriously sub-standard workmanship in safety related areas.

Inspection of the work was fou'id to be inadequate and unreliable with forged inspector initials on work which had not been inspected.

There is no assurance that the Perry reactors could be operated safely without serious malfunction.

No quality assurance.-

Res ponse The issue of quality assurance during the Perry plant construction has been admitted as a contention for the operating license hearing.

Tne contention has been restricted by the Hearing Board to the specific quality assurance implications arising from the February 1978 stop work order. At that time with the plant in the initial stages of construction, the Com-mission found major deficiencies in several areas of construction activity which indicated a major breakdown. in the quality assurance program.

Con-struction at the Perry plant was halted until Cleveland Electric Illuminating demonstrated that' these deficiencies 'had been overcome.

We are aware of the recent events in regard to-quality assurance that-have led to press articles. These two events concerned the welding of liner' plates in the suppress ~ ion pool and the installation of electrical cable.

In these. instances, either the contractor or CEI reported or detected the defects early and corrective action was taken.

In both events, stop work orders were issued, one by Newport News (the containment steel erector) and the other by CEI' to L.K. Comstock (the electrical contractor). A number'of allegations have been made regarding these events.

During the NRC investigation of the allegations, some QA problems in the electrical area have been identified. An NRC enforcement action is presently..under i

consideration and a team inspection has been scheduled to provide further details.

In the meetings with the applicant on these matters, CEI has been cooperative and r'sponsive in making corrections.

Concern No. 5 Because of the underground high, water table level (16 inches below the surface), Perry is to use a porous cement blanket and pumping. system instead of stronger foundation walls.

The complete system is untried--only parts of it--and there' is, the unanswered questi.on a,s to whether the soft shale under the cement blanket could erode and block the pores.

Failure of the pumping system could threaten the stability of the reactor building, according to NRC engineer, David Lynch.

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. l Res ponse This concern relates to the underdrain system, a system designed to draw down the groundwater level at the site. The system was required after an analysis in 1974 of the dynamic stability of safety-related structures indicated that the safety factor against overturning during a seismic event was insufficient. This insufficiency was due to the buoyancy forces associated with the normal groundwater level.

The staff requires a minimum safety factor of about 1.5 during the Operating Basis Earthquake (0BE) and about 1.1 during the Safe Shutdown Earthquake (SSE).

The underdrain system was a fully litigated issue resolved at the Perry construction permit hearing.

The normal groundwater elevation at the Perry site is 618 feet, msl. The underdrain system will maintain the groundwater at an elevation of 568 feet, msl, under normal conditions and will maintain the groundwater at an eleva-tion of about 594 feet, msl, under worst case assumptions.

With a ground-water level of 594 feet, msl, th'e safety factor for the safity-related structures against overturning during the postulated Operating Basis Earthquake (OBE) ranges. from 1.8 to 4.4 and from 1.1 to 2.5 during the Safe Shutdown Earthquake (SSE).

All of these values are within the acceptable limits which were established by the staff.

The porous concrete blanket is not the load bearing member for the plant foundation.

The plant is supported by means of appropriately designed reinforced concrete members.

The porous concrete blanket was placed in and around these supporting members to offer a path for water flow.

An elaborate system involving Class A fill is placed around and beside the.

porous concrete to act as a filter blanket to protect the porous concrete from-infiltration of fine particles present in Class B fill and existing subsoils (includes the soft shale mentioned in the concern).

The Technical Specifications for operation of the plant will require that if the water level in the pressure relief underdrain manholes exceeds elevation 570.0', the Commission shall be notified of the fact and remedial action taken.

If the Water level exceeds elevation 580.0'. the reactors will be required to shut 'down and emergency actions taken.o reduce the water level.

Note that these controls are initiated well below the 594.0' level that has been shown to be acceptable.

Concern No. 6 The Perry facility is in earthquake area, which runs diagonally through the Buffalo area, Lake Erie, northern Ohio, and angles down to Missouri. Any quake activity could disrupt the pumping system and building stability.

The Perry site has a rock fissure, which has been filled 30 feet across with cement, running diagonally across the entire site from southeast to northwest.

The extent of the fissure was unknown at the time it was decla' red to be of glacial origin.

A second and different rock fissure is in the floor of the tunnel which runs out under Lake Erie.

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Re ponse The geological fault or anomaly at the Perry site (on land) was a fully litigated issue during the construction permit hearing. Specifically, it-was determined that the faults and other irregularities in the shale at the site (a).are nontectonic in origin, (b) are the result of glacial activity, and (c) cannot be expected to cause earthquakes.

Since the CP stage hearing, similar faults were discovered in the vicinity of the intake and discharge tunnels under Lake Erie.

In a letter dated November,30,1981, the staff's consultant from the United States Geological Survey has concluded that these faults are also non-capable. Therefore, based on the available information, the staff presently believes that the seismology of the Perry location has been appropriately considered in the plant's design.

Concern No. 7 The Perry utilities have petitioned the NRC for permission to triple the size of its spent-fuel storage faciliti With no federal program demon-strated as feasible for long-term storage of spent reactor fuel, we have no assurance that the Perry spent-fuel assemblies will ever be moved from the site. According to a German study this past year, a loss of coolant in a spent-fuel storage pool, either from disruption of supply or destruc-tion of storage pool walls from earthquake or settling, could r.esult in a more widespread accident than a reactor meltdown. The storage pools lack the built-in safety systems which would mitigate the effects of a serious reactor accident.

The inadequate roads combined with population evacua-tion efforts would greatly hamper emergency assistance in the area under such circumstances.

Response

This concern was addressed at the prehearing conference for the opera-4 ting license hearing.

The spent fuel pool is a steel lined, concrete pool inside a thick reinforced concrete building. These structures are designed to withstand the worst postulated seismic event.for the Perry site.

Since the interyenor did.not identify any fault with the pool design or mecha-nism for loss of coolant, the Board has rejected this issue from the hearing.

The staff's evaluatioh of the spent fuel pool, including.its size and design.,

will appear in the Safety Evaluation Report (SER) which is expected to be issued in May 1982.

Concern No. 8 In case of accident utility insurance liability is limited under the Price-Anderson Act to the grossly inadequate $650 million [ sic] limit.

People in the area are unable to get personal insurance which will cover either property damage or health damage from radiation exposure.

It is very difficult to prove that cancers, leukemia, or birth defects years later have resulted from such radiation exposure. The 20 year statute of limitations would further limit efforts to secure just restitution.

People living within a 50 mile radius of the Perry reactors would bear most of the costs of an accident, both physically and financially.

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Response

Under the Price-Anderson Act there is a system of private funds and Government indemnity totaling up to $560 million to pay public liability claims for personal injury and property damage resulting from a nuclear incident. The Act requires licensees of commercial nuclear power plants having a rated capacity of 100,000 electrical kilowatts or more to provide proof to the NRC that they have financial protection in the form of private nuclcar liability insurance, or in some other form approved by the Commission, in an amount equal to the maximum amount of liability insurance available at reasonable cost and on reasonable terms from private sources.

That financial protection, presently $530 million, is composed of primary private nuclear liability insurar.ce of $160 million available from two nuclear. liability insurance pools--American Nuclear Insurers (ANI) and Mutual Atomic Energy Liability Underwriters (MAELU), and a secondary retrospective premium insurance layer up to $5 million per power reactor licensed to operate per incident but not in excess of $10'million for a single reactor in any With 74 commercial r.eactors operating under this system, the secondary year.

insurance layer totals $370 million.

The difference of $30 million between the financial protection layer of $530 million and the $560 million liability limit is the present Government indemnity level.

Under the present system, indemnity will be phased out as more commercial reactors are licensed and participate in the retrospective premium system.

At the time the primary and secondary financial protection layers by themselves provide liability coverage of $560 million, Government indemnity will be eliminated. Then the liability limit would increase, without any cap on the limit, in increments of $5 million for each new commercial reactor licensed.

The.

present limitation of liability of $560 million was established by the Congress so that if an incident occurred requiring the Government to pay

$500 million in indemnity (above the $60 million in liability insurance available from the pools when the Act was enacted in 1957), the Federal budget would not be greatly disturbed yet there would be a sure supply of funds to pay public liability claims resulting from the incident. Because the limitation was not meant to reflect the worst possible accident that could occur at a' nuclear power plant, the fact that various technical reports issued over' the years' acknowledge that a nuclear accident could cause damages exceeding the liability limit has not led Congress to raise the limitation.,

The comment pertaining to the inability for members of the local population to buy radiation insurance relates to the fact that property insurance policies are written with a " nuclear exclusion" clause that does not provide-coverage for damage resulting from a nuclear accident.

The questi'on of the " nuclear exclusion" in an individual's homeowner's policy h'as been

. raised numerous times over the last few years. While the Price-Anderson Act does not prohibit private insurers from offering this type of insurance, the standard fire and property insurance policies have contained the nucle.ar exclusion r.ince 1959.

Our understanding of this exclusion is that the insurers consider that property damage caused by a nuclear accident would be covered by nuclear liability insurance maintained by NRC facility licensees and that coverage for the same property damage should be excluded from the conventional homeowner's policy to avoid duplication of insurance.

Thus, if a property owner suffered damage to his property because of a i

nuclear accident, the compensation would come through nuclear liability insurance or Government indemnity as provided under the Price-Anderson Act.

u Finally, we agree that there may be difficulty in proving that cancers have resulted from radiation exposure and that the cancer latency period in many' case's exceeds 20 years.

It should be noted, however, that the 20 year statute is only a minimum and only' applies in the event of an extraordinary nuclear occurrence (ENO).

If a state.Nas a longer statute of limitations for radiation-induced injury, as many states do, then the longer state statute takes precedence. While it may be correct to state

that people living within a 50 mile radius of the Perry reactors would bear many of the health and property costs arising out of an accident, in the event of a nuclear incident involving damages in excess of the limitation of liability, "the Congress will thoroughly review the par-ticular incident and will take whatever action is deemed necessary and appropriate to protect the public from the consequences of a disaster of such magnitude",42 U.S. C. 2210(e).

Concern No. 9 If the Price-Anderson Act were rescinded, there is no assurance that the CAPCO utilities could meet the costs of such an accident as that at-Three Mile Island without being bankrupted.

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Response

~ s Any answer to this concern would be speculative on the part of the Commission.

However, the financial. capabilities of the Cleveland Electric Illuminating Company and CAPC0 to cover the costs of operation, including the-costs of reasonable foreseeable contingencies, for the Perry plants is an admitted s

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contention in the operating license hearing that is scheduled to begin this fall.

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Concern No.10 o

The operating record of American reactors has been poor, operating an average 'of about 51% of the time. With Davis-Besse it has averaged about 32%.

These long shutdown periods have caused millions of dollars to be spent for replacement power, which in all instances the customers have had to pay.

In addition, maintenance and repair from mal functions, defec-tive components and desigo, and defective workmanship have added to customer

<osts.

Mishaps of these types are amazingly common--totalling 2,800 and 2,900 in 1977 and 1978.

These have resulted in long shutdown periods and heavy costs to consumers.

Response

The operating performance of nuclear power plants has been the subject of numerous discussions. The Perry plants are boiling water reactors (BWRs).

An article published in the September 1981 issue of Nuclear Engineering International indicated that the average annual load factor (worldwide) for BWRs was 59.2%.

Due to refueling outages, demand for power and other factors, individual load factors will vary from year to year.

In the noted reference, the annual load factor for BWRs varied from 27.1% to 88.8%.

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The operating record of Davis-Besse hanno bearing on the future performance i of the Perry plant.

Even there, the' sit 0ation appears to be4mproving since on January 14, 1982, Davis-Besse officials reported that their reactor had generated power 67 percent of the' time during 1981.,Chveland Electric

'y Illuminating bds' a financial interest in the Davis-Besse plant through CAPC0 but has no association with the management or operation. of the plant.

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nuclear piant.,can' vary widely In summary, the operating performance of any'nnual ler.d factor is difficult.

from year tp year and the prediction of an a Concern.No. 11 To date, nuclear utilities have no way of estimating the costs of transpor-tation and storage of radioactive wastes, long-term.

Nor 'do they have any way of, estimating the' eventual costs of moth-bolling, entombing, or dismantling sreactors. after their perivd of service, to say nothing of the

- costs of radiation monitoring in perpetuity.

Response

As stated in response to c echrn No. 9, the financial capabilities of the utility to operate the Perry plant is an admitted contention to the hearing.

All of the above items including decommissioning will be addressed at th'at hearing.

8846W Concern No.12 The recent malfunction of the hydraulic control-rod system at Browns Ferry focused attention on a GE boiling water reactor design fault.

Failure of a shut-down system is a critical safety defect. Both Perry reactors are GE boiling water type.

Res ponse The Browns Ferry event resulted in an extensive review of the BWR scram discharge system by the staff.

From that review, several actions have been recommended by the Commission to reduce the perceived risks associated with this system.

These actions will be implemented at Perry.

Furthermore, the safety issues involved with pipe breaks in this systeni have been admitted as a contention for the Perry operating license he'aring.

Concern No.13 Letter by Ms. Cook published in the October 18, 1981 edition of The Plain Dealer (Cleveland, Ohio) captioned " China Syndrome Revisited."

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Response

Most of the concerns listed in the article were addressed at the prehearing conference in June 1981. A proposed contention on the issue of pressure vessel cracking was discussed at the prehearing conference and no basis was found to admit it.

An issue concerning the emergency core cooling system (ECCS) was admitted as a contention and the full scale 30 degree sector steam test that was performed to demonstrate the adequacy of the ECCS system will be addressed at the hearing.

The concern of water hammer in a PWR is not appropriate to the Perry BWR.

Concern No. 14 General articles on Toxic Chemical Air Pollutant's

Response

Except for the area of radioactive releases, the control of air pollutants is under the jurisdiction of other Federal and/or State agencies.

There is little. reason to believe that coatings (plastics, epoxies or acrylic latex) if used in the construction of the Perry plant would differ sig-nificantly in composition or quantity from any other general non-nuclear facility under construction.

With respect to radioactive releases, nuclear power reactors in the United States must comply with certain NRC regulatory requirements in.

order to operate.

The permissible levels of radiation in unrestricted areas.and the radioactivity in effluents to unrestricted areas are spelled out in 10 CFR Part 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Is Reasonably Achievable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents. These regulations specify limits on levels of radiation in the Station's effluent releases to the air and-water (above natural background).

They also state that no member of the general public in unrestricted areas ~shall receive a radiation dose to the total body due to Station operation of more than 3 mrems from liquid effluents, 5 mrems from noble-gas effluents, and/or 15 mrems from radio-iodines and particulates.

These radiation dose limits are established to be consistent with considerations of the health and safety of the public.

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'2Cnifeb States Senate COMMITTEE ON GOVERNMENTAL AFFAIRS SUBCOM MITTEE ON ENERGY NUCLEAR Prot.IFE. RATION AND COVERNMENT PROCESSES WASHINGTON D.C. 20310 January 11, 1982 The Honorable Nunzio J.

Palladino Chairman United. States Nuclear Regulatory Commission Washington, D.C.-20555

Dear Mr. Chairman:

I have received the attached fact sheet, " Notes on the Perry Nuclear Plant" from one of my constituents, Ms. Genevieve Cook.

The document raises what appear to be a number of troubling issues'concerning this facility.

Undoubtedly many of these matters'are being addressed in the course of the Commission's licensing proceedings for the Perry plant.

I would greatly appreciate the viewc of the Commission's staff on these matters and any other pertinent information you can provide.

Best regards.

Sincerely, nn 7

John Glenn JG/lst Enclosure

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-- [* vitsin 10 miles are the twdinn Mgb sebool, middle senool, ar.d a

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m r:at.ar setu of I-?) are two-lune, so tcat in ca:,e of t '.- run,--

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• ation, Icng strings c: r.enool buses could be bodged Ocwn and stalled e

I, reffic. Cnudren,.vno are score susceptible to radiaticn injury tnan adults, vould

• nevitably te forced to brestbc considerable radiation-contaminated air.

r 9 senools within 5 miles; 32 schools within 10 miles; insufficient tuses-^

2. A-cess to I-90, the nearest mejor throucnvay, is cidway of Vadison at route-523.

Rt.2 ends between Terry and Pticesville a,d parallels the vesterly exit cr access to I-90.

Fast-west traffic on I-90 vith a ncrtherly vicd would be traveling f:r miles in radia.

tion-contaminated air.

Toere is no adequate north-south route out cf the area.

Lane County wants Cleveland Electric to cover toe costs of disaster s'ervices.

3. Highways to and from the reactor site are ir. adequate for the 10,006 to L5,000 'cu'.ft. 'of low-level radioactive vastes, vbich must be transparted away each year. Oa-site storage 3

4 would be most unsuitable in the Perry area with its ground water problens.

3

k. Construction of the reactors at Perry was halted several times beesuse of seriously sub-standard vor,utanship in safety related areas. Inspection of the vorA was found to be h

inadequate and u:. reliable with forged inspector initials on vors which bad not been in-

• f spected. Toere is no assurance that the Perry reactors could be operated safely without serious calfunction. elo quality assurance.

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5. Because of the underground bigh water table level ( 16 inches below the surface) Perry is to use a porous cement blanket and pumping system instead of strenger foundetion valls sy The complete system is untried--only parts of it--and there is the n answered question as to vbetber the soft scale under the cement blanket could erode and block the pores.

yQ Failure of the pumping system could threaten the stability of the reactor building, g

accortling to ERC engineer, David lynch.

6. The Perry facility is in earthquake area, which runs diagonally thrc.:gh the Buffalo area, lake Eric, northern Obio, and angles down to Missouri. Any quake activity could disrupt the pumping system and building stability. Toe Perry site has a rock fissure, vbich has been filled 30 feet across with cement, running diagonally across the entire Q

site from southeast to northwest. The extent of the fissure was unknown at the time q'

it was declared to be of glacial origin. A second and different rock fissure is in the floor of the tunnel vbich runs out under lake Erie.

y T. 1be Perry utilities have petiLicoed the N E for per=ission to triple the size of its y

spent-fuel storage facilities. With no federal program demonstated as feasible for y

long-tenn storage of spent reactor fuel, we have no assurance that the Perry spect-fuel M

assemblies vill ever be moved from the site. Acceniing to a German study tais past year, (i

a loss of coolant in a spent fuel storage pool, either f rom disruption of supply or destruction of storage pool valls from earthquake or settling, could result in a more videspread accident than a reactor meltdown. The storage pools lack the built-in safety b

systems which would mitigate the effects of a serious reactor accident. The inadequste roads combined with population evacuation efforts would grectly ba:per emergency assist-V, ance in the area under such circumstances.

N h 8. In case of accident utility insurance liability is limited under the Price-Anderson Act g

to the grossly inadequate $650 million limit. People in the area are unable to get per-sonal insurance vbich will cover either property da. sage or bealth datage froc radiation exposure. It is very difficult to prove that cancers, leukemia, or birth defects years later have resulted from sueb radiation exposure. The 20 year statute of limitations

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,k vonld further limit efforts to secure just restitution. People living within a 50 mile radius of the Perry reactors would bear most cf the costs of an accident, both physically and financially.

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9. If the Price-Anderson Act were rescinded, there is no assurance the the, CAPCO utilities could m-et the costs of such an accident as that at Three Mile Island without being 9

bankrupted.

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. f. The operating record of knerican reactors has been poor, operating an average of ab

$1%'of the time.

q have caused millions of dollars to be spent for replacement power, which in all instances Q

the customers have had to pay.

In addition, caintenance and repair from calfunctions, defective components and design, and defective workmanship have added to custozer costs.

Misbaps of these types are amazingly co= mon--totalling 2,B00 and 2,900 in 1977&S. These have resulted in long abutdown periods and heavy costs to consumers.

u D 11'. To date, nue~ lear utilities have no way of est wfM E s 'of transpor stor-age of radionetive vastes,loog-term. Nor do they have any va_v,~'

as in.I the eventual w

g costs of moth-balling, entombing, or dismantlingp'crfnf ter their period of service, q

to say nothing of the costs of radiatiopnaerTWrang in ferpetuity.

s g-he recent es1 function of the hy3rnulic centrol-rod syntes at Pr0vns Ferry focused atten-lon on a OE boilin.r, vnter ressetor ci sign fwlt.

N 1ure of a shut-un systi2 is a-

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M Pt.AW DEALER. $Uh0AY. OCTOBER 18.1981 CLEVELA w C.

5-A A r7 MQsmr

China Syndrome' revisited The problem.of metal failure in water-cooled nuclear react. ors g

The ominous problem of reactor vessel cracks This same issue was among those raised dur-problems"(Bulletin of the Atomic Scientists Janu.

from the therm.at shock of cold emergency conlant titr yeart ol' metal deterioration from radiation ing the U S. Ajomic Energy Commission heartags ary 1980).

' flood.ng an overheated reactor at 3 We to 5 000 tnd intense heat (PD, Sept. 27) is not a new issue.

in,197173 on the Interim Criteria. which were Dr. Kendall's doubts of the reliabdi y of the degrees' ilow rnuch damage would be caned by t

Nor is the possibility of its resulting in a loss of-regulations of the AEC that permitted cortinued emergency core cooling systems (ECf5) under the water, hammer cliect of the sudden loss of coolant accident and consequent rneltdown of the-licensing of power reactor construction before the-accident conditions were shared by 28 AEC and pressurized reactor cooling ' mater? No one knows reactor core-safety research had been completed Dr. Ilenry Oak Itidge scientists and engineers in a prepared yet it is deplorable that the constructien of so Kendall. a neclear physicist at Massachusetts Insti-statement at the AEC hearings. In fact, there were many U S reactors was perrnatted before this re-la fact, more than 10 years ago this threat tute of TechnMogy, served as a witness for a coalt.

over 100 questions brought out which no one could quared safety research was done.

was the basis for the British rejection of the tion of more than 40 cituens ;;roups known as the answer. Tbe ECCS, a computer design, has not yet During 1980 more than 3.800 "abnoimal American water-cooled reactor as unsafe. Parlia, National Intervenors. lie testified that researchers been adequately tested, although some preliminary events" were reported among our 70 operating ment's decision was m accord with the recommen.

had not yet identified all the defects, mishaps or experiments were begun in December 1978 at the reactors. Yet despite t!as. Congress is unrhang en s

dition of Sir Alan Cottrell, British chief scientist malfunctions which could initiate a meltdown LOFT test reactor in Idaho (LOFT - loss of fluid ar. interim licensing authorization bill. w hich um..d tnd En internationally respected metallurgist. II:s.

op.nion was ::pported by a resolution signed by test). The ninth test recently reported by the NitC permit new reactors to start low-level operat.na accident.

mors than 2.200 British scientists Sir Alan cited This point was well illustrated in three serious was "to study an excessive cooldown event in a before the operating license evaluation hesrino the fact that there had been no experience with the nuclear events: the Ferma-1 partial meltdown, the pressurized water reactor."

are held Catuen participation in the hearine a to (Ifect on the reactor vessel of 40 years of opera-Brown's Ferry fire, and the Three Mile Island ept-This experiment is concerned with one of two be fu{'ther restricted is this a caw of here me go 883'n Obviously we haven't learned tion - the projected lifetime of a reactor, now sode. In fact. Victor Galinska of the U.S. Nuclear unanswered questions pertinent to the reactor ves-reduced to 30 years. I!e was especially concerned Hegulatory Commission INRC) commented that sel and core under accident conditions: ilow much

'GENEVIEVE S CMK with metal ?rnbrittirment.

TML focused attention on "long ignored safety damage to the reactor vessel and core would result wesito.

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tal Protection Agency iEPAi on a mef scheduie to i. <ue sequirements for the A s a r..

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Judge Picice is-ued an mittal opinion Wiiolife Fr.ie rat i..n. 9 n.: i., C ; n.

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ten enenucals over three sear < aeo but ing a " category" appr..a -,. n; o.

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toxicity of n.pr"-en'ew m ' - ".fl inc. SHDC attorney s hase us rsed u ith group. "Me hat e ionc mi: i "i'

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WASHINGTON. D.C.

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See next page DR 2 41982 The Honorable John Glenn United States Senate Washington, D.C.

20510

Dear Senator Glenn:

This is in response to your January 11, 1982 request that the Comission's staff provide its views on a fact sheet " Notes on the Perry Nuclear Plant,"

and three media clippings from one of your constituents. Ms. Genevieve Cook.

During the licensing review of the Perry application, all of Ms. Cook's concerns that fall within the scope of our jurisdiction have been or are.

presently under review by the staff. Some of these concerns have been fully resolved to our satisfaction while others are awaiting further infomation or study. A few of these concerns were fully litigated during the construction permit hearing held from 1974 to 1977 All of the remain-r ing concerns that are appropriate to the Commission's scope of review will be addressed during the operating license review which is currently underway.

Some of these concerns have been admitted as contentions for an operating license hearing which is currently expected to begin in Painesville, Ohio, later this fall.

Construction of the plant is not expected to be. completed until late 1983.

Prior to the start of the operating license hearing, the staff will document the results of its safety and environmental review. A Draft Environmental Statement (DES) is scheduled to be issued in the next few weeks and finalized in a Final Environmental Statement (FES) this summer. A Safety Evaluation Report (SER) covering the bulk of our review is currently expected to be issued in May 1982.

One or more supplements are likely to be required to resolve all issues.

The first such supplement is targeted for issuance in July 1982. All of Ms. Cook's concerns that are within our scope of review will be addressed in these documents.

Notwithstanding the fact that our review is still in progress, we are en-closing responses to Ms. Cook's concerns consistent with this fact.

I hope this infomation will be helpful for you to respond to your consti-

.tuent.

Sincerely, (Signed) T. A, Rehm ELD EDO t

l JThessin Willian J. Dircks WJDircks 5/ /82 f

Executive Director for Operations 3/

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ENCLOSURE Commission's Staff Responses to Ms. Cook's Concerns about the Perry Nuclear Plant 9

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Comments on Perry Plant C'oncerns Concern No. 1 and 2 There are four schools within three miles of the Perry reactors, two of.them elementary. The Perry Township High School by the old Atomic Energy Com-mission regulations would be in the exclusion zone. Within 10 miles are the Madison high school, middle school, and a couple elementary schools.

All roadways North of I-90 are two-lane, so that in case of accident and evacuation, long strings of school busses could be bogged down and stalled in traffic. Children, who are more susceptible to radiation injury than adults, would inevitably be forced to breathe considerable radiation-con-taminated air.

(9 schools within 5 miles; 32 schools within 10 miles; insufficient buses)

Access to I-90, the nearest major throughway, is midway of Madison at Route 528.

Route 2 ends between Perry and Painesville and parallels the westerly exit or access to I-90.

East-West traffic on I-90 with a northerly wind would be traveling for miles in radiation-contaminated air. 'There is no adequate North-South route out of the area.

Lake County wants Cleveland Electric to cover the costs of disaster services.

Response

These concerns are associated with the Perry Plant Emergency Plan. The Plan in its current form, Appendix 13A to the Final Safety Analysis Report (FSAR), addresses the evacuation of school children and area evacuation routes.

These matters were discussed at the prehearing conference in Painesville, Ohio on June 2,1981.

The applicant is aware of these con-cerns and is assisting the local communities in the development of the local emergency plan to resolve them.

For evacuation routing, the appli-cant has indicated that the Ohio State Highway Patrol an'd local police forces will be mobilized to maintain traffic flow and exclusion from some roadways, if necessary.

'he Emergency Plan must meet our requirements prior to issuance of an operating license for power levels above 5%.

The Energency Plan has been admitted as a contention to the operating license hearing (expected to begin in November 1982). The Lake County Board of Commissioners have been granted status as a party to this pro-ceeding.

Their primary interest in the proceedings is in regard to the development and financing df the local off-site emergency plan.

I Concern No. 3 Highways to and from the reactor site are inadequate for the 40,000 to 45,000 cu. ft. of low-level radioactive wastes which must be transported away each year. On-site storage would be most unsuitable in the Perry area with its ground water problems.

Response

Based on experience to date at operating nuclear plants, the staff has no reason to expect that the hauling of Perry low level wastes will be a major safety or traffic problem.

Low level radioactive waste will be h

,e typically enclosed in 50 or. 200 cu. ft. containers for shipment. A normal truck could easily transport four-200 cu. ft. containers, each approxi-mately 5' x 5' x 8' in size. At that rate, the annual low level waste

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could be removed in 50 to 57 separate truck trips.

This number of truck shipments should not significantly impact local traffic.

The applicant has proposed only temporary on-site storage of low level waste while

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awaiting shipment to off-site repositories.

Thus, the leak-tight con-tainers should prevent any low level waste from entering the groundwater during this temporary storage period.

Concern No. 4 Construction of the.eactors at Perry was halted several times because of seriously sub-standard workmanship in safety related areas.

Inspection of the work was found to be inadequate and unreliable with forged inspector initials on work which had not been inspected.

There is no assurance that the Perry reactors could be operated safely without serious malfunction.

No quality assurance.'

Res ponse The issue of quality assurance during the Perry plant construction has been admitted as a contention for the operating license hearing. The i

contention has been restricted by the Hearing Board to the specific quality assurance implications arising from the February 1978 stop work order. At that time with the plant in the initial stages of construction, the Com-mission found major deficiencies in several areas of construction activity which indicated a major breakdown. in the quality assurance program.

Con-struction at the Perry plant was halted until Cleveland Electric I,lluminating q

demonstrated that these deficiencies 'had been overcome.

We are aware of the recent events in regard to quality assurance that"have led to press articles.

These two events concerned the welding of liner' plates in the suppression pool and the installation of electrical cable.

In these instances, either the contractor or CEI reported or detected the

~

defects early and corrective action was taken.

In both events, stop work orders were issued, one by Newport News (the containment steel erector) i and the other by CEI' to L.K. Comstoc.k (the electrical contractor). A number of allegations have been made regarding these. events.

During the NRC investigation of the allegations, some QA problems in the electrical area have been identified. An NRC enforcement action is presently.~urider consideration and a team inspection has been scheduled to provide'further details.

In the meetings with the applicant on these matters, CEI has been cooperative and responsive in making corrections.

e Concern No. 5

-Because of the underground high, water table level (16 inches below the surface), Perry is to use a porous cement blanket and pumping system instead of stronger foundation walls.

The complete system is untried--only parts of l

it--and there~ is the unanswered questi.on a.s to whether the soft shale under the cement blanket could erode and block the pores.

Failure of the pumping system could threaten the stability of the reactor building, according to NRC engineer, David Lynch.

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Response

This concern relates to the underdrain system, a system designed to draw down the groundwater level at the site.

The system was required after an analysis-in 1974 of the dynamic stability of safety-related structures indicated that the safety factor against overturning during a seismic event was insufficient. This insufficiency was due to the bucyancy forces associated with the normal groundwater level.

The staff requires a minimum safety factor of about 1.5 during the Operating Basis Earthquake (0BE) and about 1.1 during the Safe Shutdown Earthquake (SSE).

The underdrain system was a fully litigated issue r6 solved at the Perry construction permit hearing.

The normal groundwater elevation at the Perry site is 618 feet, msl.

The underdrain system will maintain the groundwater at an elevation of 568 feet, msl, under normal conditions and will maintain the groundwater at an eleva-tion of about 594 feet, msl, under worst case assumptions. With a ground-water level of 594 feet, msl, th'e safety factor for the safety-related -

structures against overturning during the postulated Operating Basis-Earthquake (OBE) ranges. from 1.8 to 4.4 and from 1.1 to 2.5 during the Safe Shutdown Earthquake (SSE). All of these values are within the acceptable limits which were established by the staff.

The porous concrete blanket is not the load bearing member for the. plant foundation.

The plant is supported by means of appropriately designed reinforced concrete members.

The porous concrete blanket was placed in and around these supporting members to offer a path for water flow. An elaborate system involving Class A fill is placed around and beside the.

porous concrete to act as a filter blanket to protect the porous concrete from-infiltration of fine particles present in Class B fill and existing subsoils (includes the soft shale mentioned in the concern).

The Technical Specifications for operation of the plant will require that if the water level in the pressure relief underdrain manholes exceeds elevation 570.0', the Commission shall be notified of the fact and remedial action taken.

If the water level exceeds elevation 580.0', the reactors will be required to shut down and emergency actions taken to reduce the wa' er level.

Note that these controls are initiated well below the 594.0' t

level that has been shown to be acceptable.

Concern'No. 6 The Perry facility is in earthquake area, which runs diagonally thro. ugh the Buffalo area, Lake Erie, northern Ohio, and angles down to Missouri. Any quake activity could disrupt the pumping system and building stability.

The Perry site has a rock fissure, which has been filled 30 feet across with cement, running diagonally across the entire site from southeast to northwest.

The extent of the fissure was unknown at the time it was decla~ red to be of glacial origin.

A second and different rock fissure is in the floor of the tunnel which runs out under Lake Erie.

~

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Response

The geological fault or anomaly at the Perry site (on land) was a fully litigated issue during the construction permit hearing.

Specifically, it-was determined that the faults and other irregularities in the shale at the site (a) are nontectonic in origin, (b) are the result of glacial activity, and (c) cannot be expected to cause earthquakes.

Since the CP stage hearing, similar faults were discovered in the vicinity of the intake and discharge tunnels under Lake Erie.

In a letter dated November 30, 1981, the staff's consultant from the United States Geological Survey has concluded that these faults are also non-capable. Therefore, based on the available information, the staff presently believes that the seismology of the Perry location has been appropriately considered in the plant's design.

Concern No. 7.

The Perry utilities have petitioned the NRC for permission to triple the size of its spent-fuel storage facilities. With no federal program demon-strated as feasible for long-term storage of spent reactor fuel, we have no assurance that the Perry spent-fuel assemblies will ever be moved from the site. According to a German study this past year, a loss of coolant in a spent-fuel storage pool, either from disruption of supply or destruc-tion of storage pool walls from earthquake or settling, could result in a more widespread accident than a reactor meltdown.

The storage pools lack the built-in safety systems which would mitigate the effects of a serious reactor accident. The inadequate roads combined with population evacua-tion efforts would greatly hamper emergency assistance in the area under such circumstances.

Response

This concern.was addressed at the prehearing conference for the opera-ting license hearing. The spent fuel pool is a steel lined, concrete pool inside a thick reinforced concrete building. These structures are designed to withstand the worst; postulated seismic event for the Perry site. Since the intervenor did not identify.any fault with' the pool design or mecha-nism for loss of coolant, the Board has rejected this issue from the hearing.

The staff's evaluatioh of the spent fuel pool, including its size and design.,_

will appear in the Safety Evaluation Report (SER) which is expected to be issued in May 1982.

Concern No. 8 In case of accident utility insurance liability is limited under the'Prica-Anderson Act to the grossly inadequate 1650 million [ sic] limit. People in the area are unable to get personal insurance which will cover either property l

damage or health damage from radiation exposure.

It is very difficult to l

prove that cancers, letkemia, or birth defects years later have resulted l

from such radiation exposure.

The 20 year statute of limitations would l

further limit efforts to secure just restitution.

People living within a 50 mile radius of the Perry reactors would bear most of the costs of an.

accident, both physically and financially.

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Response

Under the Price-Anderson Act there is a system of private funds and Government indemnity totaling up to $560 million to pay public liability claims' for personal injury and property damage resulting from a. nuclear incident. The Act requires licensees of commercial nuclear power plants having a rated. capacity of 100,000 electrical kilowatts or more to pr. ovide proof to the NRC that they have financial protection i'n the form of private nuclear liability insurance, or in some other form approved by the Commission, in an amount equal to the maximum amount of liability insurance available at reasonable cost and on reasonable terms from private sources. That financial protection, presently $530 million, is composed of primary private nuclear liability insurance of $160 million available from two nuclear. liability insurance pools--American Nuclear Insurers (ANI) and Mutual Atomic Energy Liability Underwriters (MAELU), and a secondary retrospective premium insurance layer up to $5 million per power reactor licensed to operate per incident but not in excess of $10 million for a single reactor -in any year. With 74 commercial r.eactors operating under this system, the secondary insurance layer totals $370 million. The difference of $30 million between the financial protection layer of $530 million and the $560 million liability limit is the present Government indemnity level.

Under the present system, indemnity will be phased out as more commercial reactors are licensed and participate in the retrospective premium system. At the time the primary and secondary financial protectinn layers by themselves provide liability coverage of $560 million, Government indemnity will be eliminated. Then the liability liait would increase, without any cap on the limit, in increments of $5 million for each new commercial reactor licensed. The.

present limitation of liability of $560 million was established by the Congress so that if an incident occurred requiring the Government to pay

$500 million in indemnity (above the $60 million in liability insurance available from the pools when the Act was enacted in 1957), the Federal budget would not be greatly disturbed yet there would be a sure supply of funds to pay public liability claims resulting from the incident. Because the limitation was not meant to reflect the worst possible accident that could occur at a nuclear power plant, the fact that various technical reports issued over' the years' acknowledge that a nuclear accident could cause damages exceeding the liability limit has not led Congress to raise the limitation.,

The. comment pertaining to the inability for members of the local population to buy radiation insurance relates to the fact that property insurance policies are written with a " nuclear exclusion" clause that does not provide coverage for damage resulting from a nuclear accident. The question of the " nuclear excloion" in an individual's homeowner's policy h'as been raised numerous times over the last few years. While the Price-Anderson Act does not prohibit private insurers from offering this type of insurance, 4

the standard fire and property insurance policies have contained the nucle.ar exclusion since 1959.

Our understanding of this exclusion is that the insurers consider that property damage caused by a nuclear accident would i

be covered by nuclear liability insurance maintained by NRC facility licensees and that coverage for the same property damage should-be. excluded from the conventional homeowner's policy to avoid duplication of insurance.

Thus, if a property owner suffered ' damage to his property because of a i

nuclear accident, the compensation would come through nuclear liability insurance or Government indemnity.as provided under the. Price-Anderson Act.

l

.5 Finally, we agree that there may be difficulty in proving tha.t cancers have resulted from radiation exposura and that the cancer latency period in many' case's exceeds 20 years.

It should be noted, however, that the 20 year statute is only a minimum and only' applies in the event of an extraordinary nuclear occurrence (ENO).

If a state has a longer statute of limitations for radiation-induced injury, as many states do, then the longer state statute takes precedence. While it may be correct to state that people living within a 50 mile radius of the Perry reactors would bear many of the health and property costs arising out of an accident, in the event of a nuclear incident involving damages in excess of the limitation of liability, "the Congress will thoroughly review the par-ticular incident and will take whatever action is deemed necessary and appropriate to protect the public from the consequences of a disaster of such magnitude",42 U.S. C. 2210(e).

Concern No. 9 If the Price-Anderson Act were rescinded, there is no assurance that the CAPC0 utilities could meet the costs of such an accident as that at Three Mile Island without being bankrupted.

Response

Any answer to this concern would be speculative on the part of the Commission.

However, the financial. capabilities of the Cleveland Electric Illuminating Company and CAPC0 to cover the costs of operation, including the costs of reasonable foreseeable contingencies, for the Perry plants is an admitted contention in the operating license hearing that is scheduled to begin this fall.

Concern No.10 The operating record of American reactors has been poor, operating an average of about 51% of the time. With Davis-Besse it has averaged about 32%.

These long shutdown periods have caused millions of dollars to be spent for replacement power, which in all instances the customers have had to pay.

In addition, maintenance and repair from malfunctions, defec-tive components and design, and defective, workmanship have added to customer costs. Mishaps of these types are amazingly common--tota.lling 2,800 and 2,900 in 1977 and 1978.

These.have' resulted in long shutdown periods and heavy costs to consumers.

Response

The operating performance of nuclear power plants has been the subject of numerous discussions.

The Perry plants are boiling water reactors (BWRs).

An article published in the September 1981 issue of Nuclear Engineerino International indicated that the average annual load factor (worldwide) for BWRs was 59.2%.

Due to refueling outages, demand for power and other e

factors, individual load factors will vary from year to year.

In the noted reference, the annual load factor for BWRs varied from 27.1% to 88.8%.

7-The operating record of Davis-Besse has no bearing on the future performance of the Perry plant.

Even there, the situation appears to be improving since on January 14, 1982, Davis-Besse officials reported that their reactor had generated power 67 percent of the time during 1981.

Cleveland Electric Illuminating has a financial interest in the Davis-Besse plant through CAPC0 but has no association with the management or operation of the plant.

In summary, the operating performance of any nuclear plant can vary widely from year to year and the prediction of an annual load factor is difficult.

Concern No. 11 To date, nuclear utilities have no way of estimating the costs of transpor-tation and storage of radioactive wastes, long-term. Nor do they have any way of estimating the eventual costs of moth-bolling, entombing, or dismantling reactors after their period of service, to say nothing of the costs of radiation monitoring in perpetuity.

Response

As stated in response to concern No. 9, the financial capabilities of the utility to operate the Perry plant is an admitted contention to the hearing.

All of the above items including decommissioning will be addressed at th'at hea ri ng.

Concern No.12 The recent malfunction of the hydraulic control-rod system at Browns Ferry focused attention on a GE boiling water reactor design fault.

Failure of a shut-down system is a critical safety defect. Both Perry reactors are GE boiling water type.

Res ponse The Browns Ferry event resulted in an extensive review of the BWR scram discharge system by the staff.

From that review, several actions have been recommended by the Commission to reduce the perceived risks associated w.ith this system.

These adtions will be implemented at Perry.

Furthermore, the safety 1ssues involved with pipe breaks in this system have been admitted as a contention for the Perry operating license he'aring.

j Concern No.13 Letter by Ms. Cook published in the October 18, 1981 edition of The Plain Dealer (Cleveland, Ohio) captioned " China Syndrome Revisited."

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,e Res ponse Most of the concerns listed in the article were addressed at the prehearing conference in June 1981. A proposed contention on the issue of pressure vessel cracking was discussed at the prehearing conference and no basis was found to admit it.

An issue concerning the emergency core cooling system (ECCS) was admitted as a contention and the full scale 30 degree sector steam test that was performed to demonstrate the adequacy of the ECCS system will be addressed at the hearing.

The concern of water hammer in a PWR is no.t appropriate to the Perry BWR.

l Concern No. 14 General articles on Toxic Chemical Air Pollutant ~s

Response

Except for the area of radioactive releases, the control of air pollutants is under the jurisdiction of other Federal and/or State agencies.

There is little. reason to believe that coatings (plastics, epoxies or acrylic latex) if used in the construction of the Perry plant would differ sig-nificantly in composition or quantity from any other general non-nuclear facility under construction.

With respect to radioactive releases, nuclear power reactors in the United States must comply with certain NRC regulatory requirements in.

order to operate. The permissible levels of radiation in unrestricted areas _and the radioactivity in effluents to unrestricted areas are spelled out in 10 CFR Part 50, Appendix I, Numerical Guides for. Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As low As Is Reasonably Achievable" 'for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents. These regalations specify limits on levels of radiation in the Station's effluent releases to the air and-water (above natural background).

They also state that no member of the general public in unrestridted areas ~shall receive a radiation dose to the total body due to Station operation of more than 3 mrems from liquid effluents, 5 mrems from noble-gas effluents, and/or 15 mrems from radio-iodines and particulates.

These radiation dose limits are established to be consistent wi.th considerations of the health and safety of the public.

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